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Specht v. Comm'r of Internal Revenue

United States Tax Court
Nov 16, 2022
No. 5594-22SL (U.S.T.C. Nov. 16, 2022)

Opinion

5594-22SL

11-16-2022

DANIEL LYONS SPECHT & DIANA LYONS SPECHT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge.

On July 12, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency, nor any other determination that would permit petitioners to invoke the jurisdiction of this Court, has been issued to petitioners. Although the Court directed petitioners to file an objection, if any, to the Motion to Dismiss, petitioners failed to do so. There is no indication in the record that petitioners have been issued any notice or determination that would be sufficient to confer jurisdiction on the Court in this matter.

Accordingly, and in view of petitioners' failure to "establish affirmatively all facts giving rise to our jurisdiction," David Dung Le, M.D., Inc. v. Commissioner, 114 T.C. 268, 270 (2000), aff 'd, 22 Fed.Appx. 837 (9th Cir. 2001), it is

ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction.


Summaries of

Specht v. Comm'r of Internal Revenue

United States Tax Court
Nov 16, 2022
No. 5594-22SL (U.S.T.C. Nov. 16, 2022)
Case details for

Specht v. Comm'r of Internal Revenue

Case Details

Full title:DANIEL LYONS SPECHT & DIANA LYONS SPECHT, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Nov 16, 2022

Citations

No. 5594-22SL (U.S.T.C. Nov. 16, 2022)